United States v. MacVicar, 96 F.4th 51

Kevin MacVicar pleaded guilty to one count of possession of child pornography after a federal investigation traced illegal uploads to him.
Law enforcement discovered more than 1,000 images and 200 videos of child pornography on MacVicar's devices, some dating back to 2012.
The Presentence Investigation Report (PSI) recommended an adjusted offense level of 33 and a guideline sentence of 135 to 168 months; the government sought a 120-month sentence.
MacVicar argued for no jail or a minimal sentence based on his personal history, mental health treatment, and perceived low risk of recidivism.
The district court imposed a downwardly variant sentence of 84 months (7 years), below the guideline range, citing both mitigating and aggravating factors.
On appeal, MacVicar challenged the sentence as both procedurally flawed and substantively unreasonable.

Issue	MacVicar's Argument	Government's Argument	Held
Did the district court fail to consider MacVicar's treatment efforts and rehabilitation needs?	Court overlooked these mitigating factors	Court considered all relevant factors; need not enumerate all	No procedural error; all factors considered
Was the sentence substantively unreasonable, given MacVicar's mitigation evidence?	Sentence too long; too much weight on offense, not enough on rehab	Downward variance already granted; offense severity justified sentence	Sentence was reasonable and defensible

United States v. Gall, 552 U.S. 38 (discusses appellate standard for reviewing sentencing decisions)
United States v. Holguin-Hernandez, 140 S. Ct. 762 (clarifies preservation of reasonableness claims at sentencing)
United States v. Dixon, 449 F.3d 194 (sentencing court need not mechanically address each 3553(a) factor)
United States v. Clogston, 662 F.3d 588 (review framework for procedural and substantive reasonableness of sentence)
United States v. deJesús, 6 F.4th 141 (steep standard for overturning downwardly variant sentence on substantive grounds)